for an electronic version of the CCPA PRIVACY NOTICE TO CALIFORNIA EMPLOYEES AND JOB APPLICANTS.
Click HERE for a printable version of the information below.
Privacy Notice for California Residents
January 1, 2023
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from California consumers within the last twelve (12) months:
| A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|3. Protected classification characteristics under California or federal law.
| Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|4. Commercial information.
|Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|5. Biometric information.
||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
|6. Internet or other similar network activity.
|Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|7. Geolocation data.
|Physical location or movements.
|8. Sensory data.
| Audio, electronic, visual, thermal, olfactory, or similar information.
|9. Professional or employment-related information.
| Current or past job history or performance evaluations.
|10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
| Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|11. Inferences drawn from other personal information.
|Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete, when you perform transactions, or when you purchase products or services.
- Indirectly from you.For example, from observing your actions on our Website, when you use your debit or credit card, when you make deposits or withdrawals to/from your accounts, or when you pay your bills.
- We also receive information from third parties, such as credit reporting agencies, government agencies, law enforcement authorities, or service providers.
Use of Personal Information
We may collect, use, sell, or disclose personal information for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information with us to request a rate quote, to ask a question about our products or services, or to process a transaction, we will use that personal information to respond to your request or question and to process your transactions, accordingly. We may also save your information to facilitate new transactions in the future.We also use your information for customer service and collections purposes and for ongoing account maintenance purposes, such as providing account statements, providing access to online banking, and providing account notifications.
- To provide, support, personalize, and develop our Website, products, and services.
- To offer products and/or services that we believe may be of interest to you.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- To prevent fraud by monitoring activity to detect, investigate, and prevent potentially fraudulent transactions and other illegal activities, as well as to protect the rights and property of the Credit Union and our members;
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a liquidation or similar proceeding, in which personal information held by us about our Website users/consumers is among the assets transferred.
- To support our operations and to comply with applicable legal or regulatory requirements.
- To communicate with you via any means (including email, telephone, text message, or in person) about products, services, and events offered by the Credit Union and others, as well as to provide news and information we think will be of interest to you.
- To respond to your comments, questions, and customer service requests, as well as to send you support notices, updates, security alerts, and administrative messages (such as changes to our terms, conditions, and policies).
- To monitor and analyze trends, usage, and activities in connection with our products and services.
- To audit the quality and efficacy of our work for compliance, controls, and other risk management.
- To improve our products and services by identifying issues with existing products and services, enhancing existing products and services, and creating new products and services.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Disclosure or Sale of Personal Information
In the preceding twelve (12) months, the Credit Union has disclosed for a business purpose or sold the following categories of personal information:
- Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code Section 1798.80(e)) .
- Protected classification characteristics under California or federal law.
- Commercial information.
- Biometric information.
- Internet or other similar network activity.
- Geolocation data.
- Sensory data.
- Professional or employment-related information.
During the previous 12 months, the Credit Union has disclosed for a business purpose or sold your personal information to the following categories of third parties:
- Service providers, including statement printers, and mailing houses.
- Outside companies or organizations that host, maintain, manage, or provide other services to us in relation to our products and services.
- Third parties that provide financial products and services to our members such as our card processors, online banking provider, and bill pay provider.
- Companies related by common ownership or control. These companies can be financial and nonfinancial companies.The Credit Union’s affiliates include financial companies such as CUNA, Deluxe.
- Government agencies, which include public authorities and law enforcement agencies, to respond to a lawful request, or to provide information we believe is important or required under applicable law.
- For other legal reasons, such as to monitor compliance with and to enforce our terms and conditions; to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect against potential or actual fraud, money laundering, terrorism, or other illegal activity; and for risk management purposes.
- We may also share information with outside accountants, auditors, lawyers, and other outside professional advisors to the Credit Union, subject to a requirement that such advisors keep your information confidential.
- Outside companies or organizations, including credit bureaus and other consumer reporting agencies, for routine and required reporting.
- Mortgage companies, securities broker-dealers, insurance companies, and direct marketing companies.
The Credit Union does not have actual knowledge that it sells the personal information of minors under 16 years of age.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
The Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, selling or sharing that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- If we sold your personal information, or if we disclosed your personal information for a business purpose, you have a right to request that we disclose the following information to you:
- The categories of personal information that we collected about you.
- The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold.
- The categories of personal information that we disclosed about you for a business purpose.
We shall not disclose, in response to a request to know, a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. We shall, however, inform you with sufficient particularity if we have collected that type of information. For example, we may respond that we collected “unique biometric data including a fingerprint scan” without disclosing the actual fingerprint scan data.
If we deny your verified request to know specific pieces of personal information, in whole or in part, because of a conflict with federal or state law, or an exception to the CCPA, we will inform you and explain the basis for the denial, unless prohibited from doing so by law. If the request is denied only in part, we will disclose the other information sought by you.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising ), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If we comply with your request, we will maintain a record of the request as required by law.
In cases where we deny a request to delete, we will do all of the following:
- Inform you that we will not comply with your request and describe the basis for the denial, including any conflict with federal or state law, or exception to the CCPA, unless prohibited from doing so by law statutory and regulatory exception therefor;
- Delete your personal information that is not subject to the exception; and
- Not use your personal information retained for any other purpose than provided for by that exception.
If we store any personal information on archived or backup systems, we may delay compliance with your request to delete, with respect to data stored on the archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
Rights to Correct
You have the right to request that we correct personal information that we maintain about you. If we cannot verify your identity, we may deny the request to correct. In such case, the Credit Union will inform you that your identity cannot be verified. In determining the accuracy of the personal information that is the subject of your request to correct, the Credit Union will consider the totality of the circumstances relating to the contested personal information. We may deny your request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
If we comply with your request to correct, we will correct the personal information at issue on our existing systems and implement measures to ensure that the information remains corrected. We will also instruct all of our service providers and contractors that maintain the personal information at issue pursuant to their written contract with us to make the necessary corrections in their respective systems. Our service providers and contractors must comply with our instructions to correct the personal information or enable the Credit Union to make the corrections. If we, a service provider, or a contractor stores any personal information that is the subject of your request to correct on archived or backup systems, we and our service providers and contractors may delay compliance with your request to correct, with respect to data stored on the archived or backup system, until the archived or backup system relating to that data is restored to an active system or is next accessed or used.
We will accept, review, and consider any documentation that you provide us in connection with your request to correct whether provided voluntarily or as required by us. You should make a good-faith effort to provide us with all relevant information available at the time of your request.
We may require you to provide documentation if necessary to rebut our own documentation that the personal information is accurate. In determining the necessity of the documentation requested, we will consider the following:
- The nature of the personal information at issue (e.g., whether it is objective, subjective, unstructured, sensitive, etc.).
- The nature of the documentation upon which we consider the personal information to be accurate (e.g., whether the documentation is from a trusted source, whether the documentation is verifiable, etc.)
- The purpose for which we collect, maintain, or use the personal information. For example, if the personal information is essential to the functioning of the Credit Union, we may require more documentation.
- The impact on you. For example, if the personal information has a negative impact on you, we may require less documentation.
Any documentation provided by you in connection with your request to correct will only be used and/or maintained by the Credit Union for the purpose of correcting your personal information and to comply with the record-keeping obligations under the CCPA.
We will implement and maintain reasonable security procedures and practices in maintaining any documentation relating to your request to correct.
We may delete the contested personal information as an alternative to correcting the information if the deletion of the personal information does not negatively impact you, or if you consent to the deletion. For example, if deleting instead of correcting inaccurate personal information would make it harder for you to obtain a job, housing, credit, education, or other type of opportunity, we will process the request to correct or obtain your consent to delete the information.
In responding to a request to correct, we will inform you whether we have complied you’re your request. If we deny your request to correct in whole or in part, we will do the following:
- Explain the basis for the denial, including any conflict with federal or state law, exception to the CCPA, inadequacy in the required documentation, or contention that compliance proves impossible or involves disproportionate effort.
- If we claim that complying with your request to correct would be impossible or would involve disproportionate effort, we will provide you with a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request. We will not simply state that it is impossible or would require disproportionate effort.
- If we deny your request to correct personal information collected and analyzed concerning your health, we will also inform you that you may provide a written statement to us to be made part of your record per Civil Code section 1798.185, subdivision (a)(8)(D). We will explain to you that the written statement is limited to 250 words per alleged inaccurate piece of personal information and we will include that you must request that the statement be made part of your record. Upon receipt of such a statement, we will include it with your record.
- If the personal information at issue can be deleted pursuant to a request to delete, we will inform you that you can make a request to delete the personal information and provide instructions on how you can make a request to delete.
We may deny your request to correct if we have denied your request to correct the same alleged inaccuracy within the past six months of receiving the request. However, we must treat the request to correct as new if you provide new or additional documentation to prove that the information at issue is inaccurate.
We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. We will inform you that we will not comply with the request and will provide an explanation why we believes the request is fraudulent or abusive.
Where we were not the source of the information that you contend is inaccurate, in addition to processing your request, we may, but we are not required to, provide you with the name of the source from which we received the alleged inaccurate information.
Upon request, we will disclose specific pieces of personal information that we maintain and have collected about you to allow you to confirm that we have corrected the inaccurate information that was the subject of your request to correct. This disclosure shall not be considered a response to a request to know that is counted towards the limitation of two requests within a 12-month period as set forth in Civil Code section 1798.130, subdivision (b).
With regard to a correction to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics, we will not disclose this information, but we may provide a way to confirm that the personal information we maintains is the same as what you have provided.
Exercising Your Rights
To exercise your right to know, delete, or correct described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, a Power of Attorney or letters of conservatorship must be on file with the credit union.
You may only make a verifiable consumer request for access twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Member Number; Full Name; email address; phone number; and home address.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account via online banking sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will confirm our receipt of a request to know, a request to delete, or a request to correct within ten (10) business days. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response through that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In responding to a request to know, we will provide all the personal information we have collected and maintain about you (subject to any exclusions set forth in the CCPA) on or after January 1, 2022, including beyond the 12-month period preceding our receipt of the request, unless doing so proves impossible or would involve disproportionate effort or you request data for a specific time period. That information shall include any personal information that our service providers or contractors collected pursuant to their written contract with us. If we claim that providing personal information beyond the 12-month period would be impossible or would involve disproportionate effort, we will provide you with a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot provide personal information beyond the 12-month period. We will not simply state that it is impossible or would require disproportionate effort. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Opt-Out and Opt-In Rights
The CCPA gives you the right to tell us not to sell or share your personal information with third parties by opting-out of such information sales or sharing. However, the CCPA also states that we are not required to provide you with the right to opt-out if we only sell or share your personal information with our service providers or contractors pursuant to a written contract that meets specific requirements, such as the requirement that we only sell or share your personal information to the extent that is reasonably necessary for the service provider or contractor to carry-out the contracted for business purpose and provided that the service provider or contractor agrees only to use your personal information for that purpose. You do not have the right to opt-out because we not sell or share your personal information outside of an exception that allows us to do so.
In addition, the CCPA gives you the right to limit our use or sharing of your sensitive personal information. However, the CCPA also states that we are not required to provide you with the right to limit our use or sharing of your sensitive personal information so long as we only share it for the specific purposes set forth in Section 7027(m) of the regulations implementing the California Privacy Rights Act. We are not required to provide you with the right to limit our use or disclosure of your sensitive personal information because we only use or disclose such sensitive personal information for the following purpose(s):
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. For example, a consumer’s precise geolocation may be used by a mobile application that is providing the consumer with directions on how to get to specific location. A consumer’s precise geolocation may not, however, be used by a gaming application where the average consumer would not expect the application to need this piece of sensitive personal information.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose. For example, a business may disclose a consumer’s log-in information to a data security company that it has hired to investigate and remediate a data breach that involved that consumer’s account.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose. For example, a business may use information about a consumer’s ethnicity and/or the contents of email and text messages to investigate claims of racial discrimination or hate speech.
- To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose. For example, a business may disclose a consumer’s geolocation information to law enforcement to investigate an alleged kidnapping.
- For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business. For example, a business that sells religious books can use information about its customers’ interest in its religious content to serve contextual advertising for other kinds of religious merchandise within its store or on its website, so long as the business does not use sensitive personal information to create a profile about an individual consumer or disclose personal information that reveals consumers’ religious beliefs to third parties.
- To perform services on behalf of the business, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose. For example, a business may use information for maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose. For example, a car rental business may use a consumer’s driver’s license for the purpose of testing that its internal text recognition software accurately captures license information used in car rental transactions.
- For purposes that do not infer characteristics about the consumer. For example, a business that includes a search box on their website by which consumers can search for articles related to their health condition may use the information provided by the consumer for the purpose of providing the search feature without inferring characteristics about the consumer.
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. You may submit an opt-in request by completing the opt-in form available here: link. Consumers who opt-in to personal information sales may opt-out of future sales at any time submitting an opt-out request by completing the opt-out form available here: link.
If the right to opt-out is applicable to you and you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by submitting a request to opt-in by completing the opt-in form available here: link.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by submitting a request through our Online Banking page.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights (including an employee’s, job applicant’s, or independent contractor’s rights not to be retaliated against for the exercise of their CCPA rights). Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to this Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice on our Website and update the Notice’s last updated date.
(800) 537-8491, extension 3181
First Financial Credit Union
Attn: Risk Management Department
PO Box 1078
West Covina, CA 91793-1078